Support that the findings for the fiscal years 2011 and 2014 NEDCO activity were adequately resolved or repay its program $105,688 from non-Federal funds.

Ensure that the remaining $153,191 budgeted for the 2010 NEDCO activity meets HUD requirements or amend the use of funds to another CDBG-eligible activity.

Develop and implement procedures to ensure that City employees responsible for desk and onsite monitoring reviews and its subrecipients are aware of HUD and subrecipient requirements for each type of activity funded.

Improve and implement its desk and onsite monitoring policies and procedures to strengthen its capacity to perform effective desk and onsite monitoring reviews of subrecipients and for using a risk assessment to schedule monitoring visits.

Develop and implement policies and procedures for reviewing expenses charged to CDBG from other City departments.

Develop and implement a recurring training plan for City CDBG staff to ensure knowledge of HUD regulations and requirements.

Document and submit all activities to HUD for written approval to ensure that they are eligible activities that meet the CDBG national objective requirements before funding until recommendations 1B, 1J, and 1M to 1P are adequately implemented. This should include documenting all correspondence with HUD, including review and approval.

Document and submit all payments to HUD for written approval before reimbursement until recommendations 1B, 1J, and 1M to 1P are adequately implemented. This should include documenting all correspondence with HUD, including review and approval.

Develop adequate procedures outlining steps for tracking monthly grant expenditures, reprogramming funds for stalled activities, managing program income, and allocating costs as required by Federal Register Notice 83 FR 5844 and the grant agreement with HUD.

Ensure that the financial management system for the 2017 CDBG-DR grant is capable of providing information by activity type and grant number.

Develop and implement a financial management system for its 2008 CDBG-DR grant and ensure that it tracks program funds to a level that supports compliance with HUD requirements. At a minimum, the accounting system must reflect disbursements by grant, activity, and activity type and properly account for assets, liabilities, and program income.

Review and update its 2017 CDBG-DR policies and procedures to prevent duplication of benefits and ensure that these are comprehensive and all applicable activities are included, including but not limited to the Small Business Financing Program and the Construction and Commercial Revolving Loan program.

Negotiate with the SBA, within 30 days of the issuance of this audit report, to extend its data-sharing agreements for the term of the expenditure requirements set forth in public laws or the Federal Register in relation to the 2017 and 2008 disasters.

Negotiate with Puerto Rico’s Insurance Commissioner and with other CDBG-DR grantees, within 30 days of the issuance of this audit report, to establish data-sharing agreements for the 2017 CDBG-DR grant disaster, any open disaster recovery grants, and future disasters.

Complete, within 30 days of the issuance of this audit report, the review for preventing duplication of benefits associated with its 2008 CDBG-DR grant and pursue appropriate remedies for any instances of noncompliance found.

Review and update its procurement policy for the 2017 CDBG-DR grant to address weaknesses identified, including but not limited to required contract clauses, processes for soliciting and accepting noncompetitive proposals, and performing cost or price analyses before receiving bids or quotations, among other issues.

Ensure that the 2017 CDBG-DR procurement policy addresses the establishment of a contract register that, at a minimum, contains the procurement information specified in section 3.8 of HUD’s Buying Right Guide regarding the PRDOH’s acquisitions of goods and services, as well as of its subrecipients and partners.

Establish procurement policies and procedures for the 2008 CDBG-DR grant to ensure compliance with 2 CFR 200.318-326, including but not limited to procedures to ensure full and open competition, supporting independent cost estimates, properly documenting the procurement history, and including required clauses in contracts, among other issues.

Continue to fill its vacancies with qualified and trained staff, thus ensuring that staffing levels remain adequate to administer the 2017 and 2008 CDBG-DR grant funds.

Structure the internal audit division within a framework that can ensure its organizational independence and allow the internal audit activity to fulfill its responsibilities.